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HQ 956101

July 18, 1994

CLA-2 CO:R:C:T 956101 BC


TARIFF NO.: 4602.10.5000

Jane L. Taeger
Import Manager
810 Oregon Avenue
Suite E
Linthicum, MD 21090

RE: Classification of a maize straw floor mat with textile adornments; plaiting material

Dear Ms. Taeger:

This responds to your letter of March 11, 1994, wherein you requested a binding tariff classification ruling for a floor mat made of maize straw. You submitted a sample for our examination. We have reviewed the matter and our decision follows.


The merchandise at issue, as represented by the sample, is an oval-shaped mat stated to be made of maize straw. It measures 35 inches long by 24 inches wide. The straw material is plaited (braided) to form strands (about 8 mm by 5 mm) which are then sewn together in parallel rows to form various patterns, including oval, circular, and triangular patterns. These patterns are sewn together to form the mat and to provide a decorative presentation. Two circular and two triangular patterns are sewn together to form the generally oval-shaped center portion of the mat; the oval patterns, parallel rows of strands sewn together, form the outer portion of the mat. In between the inner circles and triangles and the outer oval-shaped parallel rows are decorative patterns consisting of small circles and rows of short strands aligned perpendicular to the rows of the inner circles and outer ovals. Some of the strands in the mat are dark brown in color (in contrast to the other lighter colored strands), adding to the decorative appearance.

The top side of the mat is adorned with two 7 and 1/2 inch diameter circles said to be made of needlepoint canvas with wool thread stitching. The canvas is in the shape of a circle and the wool stitching forms green leaves and colored flowers. These canvas circles are sewn onto the straw plaiting material; they cover two circles that form the centers of the two adjacent circles in the center portion of the mat.

You contend that the mat should be classified under subheading 4601.20.8000, Harmonized Tariff Schedule of the United States Annotated (HTSUSA), which provides for plaiting materials, plaits, and similar products of plaiting materials: . . . mats . . . : other: floor coverings.


What is the proper classification for the straw mat at issue?


Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is accomplished in accordance with the General Rules of Interpretation (GRI's). The systematic detail of the Harmonized System is such that virtually all goods are classified by application of GRI 1, that is, according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that goods cannot be classified solely on the basis of GRI 1, and if headings and legal notes do not otherwise require, the remaining GRI's will then be applied in numerical order. Further, the Explanatory Notes (EN's) to the Harmonized Commodity Description and Coding System (HCDCS), which represent the official interpretation of the tariff at the international level, facilitate classification under the HTSUS by offering guidance in understanding the scope of the headings and GRI's. Accordingly, the GRI's and EN's are utilized as the basis for the classification determination discussed below. (See Treasury Decision 89-80, endorsing use of the EN's in the classification of goods. 23 Cust. Bull. 379 (1989), 54 Fed. Reg. 35,127 (August 23, 1989).)
As above, you contend that classification should be under subheading 4601.20, HTSUSA. Another possible classification for the mat at issue is subheading 4602.10, HTSUSA. Thus, the competing headings are 4601 and 4602, HTSUSA. They are as follows:

4601 Plaits and similar products of plaiting materials, whether or not assembled into strips; plaiting materials, plaits and similar products of plaiting materials, bound together in parallel strands or woven, in sheet form, whether or not being finished articles (for example, mats, matting, screens):

4601.10 Plaits and similar products of plaiting materials, whether or not assembled into strips . . .

4601.20 Mats, matting and screens of vegetable materials: . . .

4602 Basketwork, wickerwork and other articles, made directly to shape from plaiting materials or made up from articles of heading 4601; articles of loofah:

4602.10 Of vegetable materials: Other

While it is clear that mats are provided for in 4601.20, HTSUSA, the EN's indicate that not all mats are so classified (see HCDCS, Vol. 2, p. 651-54). According to the EN's, goods covered under heading 4601, HTSUSA, including mats, are "either formed of strands woven together, generally in the manner of warp and weft fabrics, or they may be made of parallel strands placed side by side and maintained in position in the form of sheets by transverse binding threads or strands holding the successive parallel strands." This language indicates that the mats covered by heading 4601, HTSUSA, must be woven with a generally warp and weft-like orientation or must consist of parallel strands maintained in a side by side orientation in the form of sheets. The mat at issue was not constructed in either of these ways and does not conform to either of these patterns. Rather, it consists of several component pieces made up of parallel strands of straw. These several components - the circular, triangular, and oval components (referred to as "patterns" in the "FACTS" section), as well as the more decorative component consisting of small circles and perpendicular strands - are sewn together to form an oval-shaped mat. This construction and pattern are clearly different from the EN's description, above.

In addition, the EN's indicate that although certain additional materials, other than plaiting materials, may be present in the covered products - for example, spun textile yarn, reinforcement, backing, or lining made of woven textile fabric or of paper - these other materials must serve primarily for assembly or reinforcement purposes. The needlepoint canvas circles sewn into the mat at issue are purely decorative in nature. They do not provide an assembly or reinforcement function.

Thus, the mat at issue does not qualify as a mat covered under heading 4601, HTSUSA, because its construction differs from that of covered mats (and other covered goods) and the non-plaiting material present therein serves an other than assembly or reinforcement function.

The EN's for heading 4602, HTSUSA, state that the heading covers the following articles:

(i) articles made directly to shape from plaiting materials;

(ii) articles made up from the already assembled products of heading 4601, i.e., from plaits or similar products, or from the products bound together in parallel strands or woven in sheet form. . . .; and

(iii) articles of loofah (gloves, pads, etc.) lined or not.

We consider the materials that make up the mat at issue (the various components) to be already assembled products of heading 4601, HTSUSA. (Had the components been imported in bulk, they would be classifiable under that heading.) Thus, the mat is made up as described in (ii) above. Hence, we conclude that the mat is classifiable under heading 4602, HTSUSA.


The floor mat at issue, made from components consisting of straw plaiting materials, is classifiable under subheading 4602.10.5000, HTSUSA, which provides for basketwork, wickerwork and other articles, made directly to shape from plaiting materials or made up from articles of heading 4601: of vegetable materials: other: other. Certain goods classifiable under subheading 4602.10.50, HTSUSA, are eligible for a reduced duty rate under subheading 9903.10.38, HTSUSA, until December 31, 1994. This special rate is applicable to the mat at issue. The General column 1 rate of duty for that subheading is 2.3% ad valorem.


John Durant, Director

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